REACH Position Paper

Dear Customer,

As a leading manufacturer of threading, gauging, clamping and milling tools we have been closely engaged for a long time already with the rules for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) of the EU, which have come into effect as of 1 June, 2007.

The time-table set by REACH is scheduling an end of the preparatory registration period for 30 November, 2008. The time-table for the subsequent registration depends on the production volume and the danger potential of the substances in question.

For a better exchange of information, we have formed a team inside our company group which will concern itself intensively with the realisation of the requirements as defined by REACH, and which will, among other activities, participate in informative meetings of competent professional associations.

EMUGE-FRANKEN is, in the sense of REACH, exclusively a so-called Downstream User. In this role, we depend mainly on the declarations of our suppliers for planning our future modus operandi. One important part of this planning is to stay in close contact with our suppliers, in order to ascertain the availability of raw materials in accordance with the regulations of REACH.

For our products, we use well-known and commercially available substances. We can consequently assume that our suppliers will pre-register these substances for our use, and subsequently register them. We must, however, point out that a list of the application categories has not yet been definitely adopted. The consulting in this direction is still in progress. We would like to underline that some manufacturers and importers of chemicals still need to position themselves.

Nevertheless, we understand the concern of our customers to have in their hands a statement that will assure them of the availability of time-proven and successful products. For this reason, we are striving, in close cooperation with our suppliers, to be able to continue supplying our products to our customers in the good quality they are accustomed to.

EMUGE-FRANKEN takes the obligations set by REACH, and the regulations connected with them, very seriously, and observes the effects of REACH on the European industry in close contact with customers and suppliers.